Just wanted some insight on how other FIs are handling the following scenario when filing a SAR:

A credit card client of ours makes payments to her credit card account by depositing multiple monetary instruments at one of our retail branches. These MIs were purchased at various MSBs.

Now the question - when it comes to checking off SAR Item 63 and 64 (FI's & Branch's role), what should we be checking off? The FinCEN SAR guidance speaks to the deposit accounts but I could not locate anywhere pertaining to the use of MIs to paying credit card accounts. My gut instinct tells me it's "better" to check off the branch as the "Paying location", as we're not selling these MIs or products.

How are you handling this? Has there been additional FinCEN guidance addressing this?

See Question 18.

First, they left the question from the old MSB SAR on the FinCEN SAR by mistake and they are struggling to find some rationale for its use. Second, I don't think your institution is either the paying or selling location, but I rely on Principles of Banking for that conclusion, not the Q & A I linked.

Related Thread

Since you did not cash a check or sell a check, you may not check either box.

Ken is the faster typist today

Just thought I would throw in something. I recently worked on a case involving over $30,000 in money orders that were purchased using stolen credit card information. Do you know how your client paid for her MIs?

Thank you all for your inputs. After doing a tedious research to no avail, we decided stick to our "internal approach", as there seems to be no right or wrong answer - let alone this is not even a critical field to begin with.

@Retread That is an interesting case indeed. How did you ever find out the MOs were purchased using stolen CC info? The perpetrator must've been an honest crook As for our customer, we do not know the source.

What is your internal approach? Critical or not, reporting it wrong is not the answer.

Not for nothing, but there does seem to be a "right" approach - outlined to you by a renowned BSA/AML expert (Ken). And I can't speak for all BSA folks, but the ones I know are limiting that field the way others described. You should go with that.